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Taitz v Astrue - Motion for Reconsideration(Draft) - Obama's Social Security Number

Taitz v Astrue - Motion for Reconsideration(Draft) - Obama's Social Security Number

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Taitz v Astrue - Motion for Reconsideration - Obama's Social Security Number - http://www.BirtherReport.com
Taitz v Astrue - Motion for Reconsideration - Obama's Social Security Number - http://www.BirtherReport.com

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Published by: ObamaRelease YourRecords on Sep 09, 2011
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01/11/2014

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Dr. Orly Taitz, ESQ pro se29839 Santa Margarita Parkway, STE 100Rancho Santa Margarita CA 92688Tel: (949) 683-5411; Fax (949) 766-7603
E-Mail: dr_taitz@yahoo.com,orly.taitz@gmail.com UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIADr. Orly Taitz, in
 pro se
) Hon. Royce C. Lamberth)Plaintiff, )) Case No. 11-cv-00402v. )) Motion for ReconsiderationMichael Astrue, Commissioner of the )Social Security Administration, )) [Request for Oral argument) to be held within 20 days])Respondent . )
_________________________________)
Filed: September 8, 2011
Dr. Orly Taitz, Esq. (Hereinafter “Taitz”) submits this motion for 
reconsideration and respectfully requests emergency hearing and oral argument onthe merits within 20 days, based on newly discovered information and based on anassertion of clear error and manifest injustice, pursuant to Federal Rule of CivilProcedure 59(e). This motion is based on the instant Memorandum of points andauthorities, exhibits herein, and any matters present at oral argument.
Copy courtesy of www.ObamaReleaseYourRecords.com - www.BirtherReport.com
 
 
MEMORANDUM OF POINTS AND AUTHORITIES
While generally disfavored, a motion for reconsideration under Federal Ruleof Civil Procedure section 59(e) may be granted in circumstances where a partypresents new evidence not reasonably available prior to the judgment, or where itis shown that the prior ruling was clearly erroneous or manifestly unjust.
See e.g., Lake Hill Motors, Inc. v. Jim Bennett Yacht Sales, Inc.
(7
th
Cir. 2000).In support of the instant motion, Taitz presents both newly discoveredevidence and argues clear error and manifest injustice of this Honorable Court'sAugust 30, 2011 Memorandum Opinion granting the Defendant's SummaryJudgment Motion. Taitz presents the following for this Honorable Court'sconsideration:
 Newly Discovered Information and Evidence Warrants Reconsideration and  Denial of Defendant's Summary Judgment Motion.
a. Plaintiff Presents New Evidence Regarding Waiver of Privacy byPrior Public Release of Social Security Number 
...After Taitz submitted her opposition to motion for summary judgment, sheappeared on a number of radio shows. During one of the shows, talk show host,Mr. Doug Hagmann, who is also a private investigator, related to Taitz that whenMr. Obama originally posted his tax returns on WhiteHouse.gov, he left his fullSocial Security number on one of the pages, and it was the same Connecticut socialsecurity number which is listed in the sworn affidavits of investigators Sankey,Daniels and Sampson which were previously submitted to this court.
 
Based on this information Taitz did her due diligence and furtherinvestigated the matter. She e-mailed thousands of interested citizens in an effort toascertain if they have records of the initial posting on WhiteHouse.gov of 
Obama’s tax returns with his full social security number. She received reports, that
on April 15, 2010 the
 Huffington Post 
 
 published an article about Obama’s tax
returns being released and posted on White House.gov, they provided the link tothe newly released reports.Originally, as the tax returns were posted an employee who posted them did
not “flatten”
the file. What it meant is that if any person were to open this file inAdobe illustrator computer application, this person could see layers of alterationsmade to the file. It showed on page 43 of Obama's 2009 return a full unredactedsocial security number, that started with 042. (
See
attached.Exhibit 1(a) and exhibit1(b))The moment this information was posted on the White House official website it became public knowledge. It was not done by any illegal activity of thePlaintiff, it was done by Barack Obama himself or one of his employees, who wasauthorized by Obama to post this tax return on the web. Taitz did not force Obamato post his full unredacted SSN on line. This number became public record.As set forth in Plaintiff's earlier Opposition, every State had certain digitsassigned to it as the first 3 digits of SSN. The first three digits in the number on thetax return in question was assigned to Connecticut. Of course, Obama was never aresident of Connecticut. Even without confirmation from the Social Securityad
ministration, it raises a concern well beyond “bare suspicion” of wrongdoing
which, together with the substantial public interest in this matter, justifies releaseof SS-5 application to this number, or at least a redacted SS-5.Adobe Ilustrator expert, Mr. Chito Papa, provided Taitz a sworn affidavit,(Exhibit 1, hereto) stating that indeed the initial file, posted by Obama, was not

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